From: Arnold D. Sobol [sobola@acm.org]
Sent: Thursday, January 02, 2003 3:36 PM
To: SEC
Subject: Comments on File No. S7-52-02

First let me compliment the committee on its good work.

My only criticism concerns the lack of a definition for "corporate
websites". I did not notice any differentiation between public and private
websites as are often referred to as Internet and intranet infrastructures.
You might clarify the usage of this term unless it is done elsewhere.

My company markets a software product that produces both printed Forms 3, 4
and 5 and files to transmit to EDGAR. My comments are addressing the minimal
information that is currently available regarding the type of third-party
service agents you are going to support and reduced content filings.

Our product provides tools to assist users in the following areas that may
not be addressed by your new web site. Historical automated records are kept
to support amended filings, determine the cost basis of holdings and to
provide history reports. A footnote library is maintained enabling users to
footnote fields within insiders, security classes, transactions or the next
filing for an insider. Current balances are maintained for all security
classes with the user having the option of printing only the balances for
the classes that do not have any transactions to report in the filing.
Transactions such as those related to 401K plans that are not reported, but
are reflected in the balances  can be entered when they occur and will
automatically effect the balance whenever that security class is reported.

When you said you want to encourage others to try to improve upon your user
interface I hope the above was the sort of thing you had in mind. We provide
a software product to assist the users in filing and not a filing service as
some other third party vendors do. It is our goal to have our system to
continue to be the single data entry point both for filing and the functions
described above. With the short time required to report these transactions
and your efforts to provide an easy to use interface I am sure many of our
clients will not want to involve a third party in the filings but will want
to continue to do it themselves.

The "reduced content filing" seems to provide the appropriate interface
between our system and EDGAR. Let me propose an approach to this. The user
would create an EDGAR interface file containing the form content with our
system. They would then log on to the new EDGAR site providing the necessary
header information identifying themselves, the issuer and the form to be
filed. Once they were satisfied that that was correct they would then add
the EDGAR interface file as an attachment identifying it as containing the
form content. You would then parse the attachment putting all of the user
supplied information into your data base just as if it was entered online
and do the same editing. The user would then be able to correct any errors
or make any changes online or could create another EDGAR interface file and
submit it. This can potentially reduce the time users would be online.

Let me propose an ASCII XML text file as an appropriate medium for this
interface. If every box and column is tagged and can contain a tagged
comment reference the online system could process the information the same
way whether it is entered manually or in an attached file.

As a third-part software provider I am looking forward to the opportunity to
work with you during the design, creation, testing and implementation of
this ground breaking approach to the electronic dissemination of
information.


Arnold D. Sobol
Partner
R&W Software
1115 19th Street Unit 9
Santa Monica CA  90403
www.randwsoftware.com
sobola@acm.org
310-453-5718